October 10, 2025
Ms. Kelly Denit
Director, Office of Sustainable Fisheries
NOAA National Marine Fisheries Service
Transmitted via email: nmfs.seafoodstrategy@noaa.gov
Re: Executive Order 14276, Restoring America’s Seafood Competitiveness
Dear Ms. Denit:
Thank you for the opportunity to comment on Executive Order 14276, Restoring America’s Seafood Competitiveness.
AFS is the world’s oldest and largest professional society of scientists, industry, and natural resource managers working in the fields of fisheries and aquatic sciences. The society works to enhance knowledge and promote the sustainability of fishery resources and aquatic ecosystems by fostering scientific progress, supporting the development of fisheries professionals, and advancing the use of the best available science in policy making. A specific role that AFS plays is to connect scientists and fishers, facilitating and expanding the use of cooperative research.
Natural resource management in this country fundamentally relies on science and guided decisions that promote the sustainable use and enjoyment of public resources for all citizens and future generations. This effort is supported by a dedicated and highly skilled professional workforce. As a result, the U.S. is one of the highest-yielding capture fisheries producers worldwide.1 Yet despite having achieved a high level of sustainable domestic seafood supply, the U.S. is also the largest importer of seafood.1 Risking seafood supply by disregarding scientific advice means that potentially filling domestic demand for seafood would fall on increasing imports. Instead, we urge you to maintain appropriate regulations and restore funding and staffing to ensure that NOAA’s National Marine Fisheries Service can sustainably manage our nation’s marine fisheries. Furthermore, the long-term risk to the fishing industry resulting from funding reductions for the science that supports the development of catch limits and other management decisions is likely to be catastrophic to this important economic sector.
Best Scientific Information Available to Guide Fisheries Management
The U.S. system is among the most successful in the world in preventing overfishing and rebuilding overfished stocks, ensuring that fishing opportunities can be sustained for years to come. Sustainable fisheries depend on functioning management systems2, with science serving as the cornerstone. Continuous monitoring of fish abundance and catch, rigorous stock assessments, the development of annual catch limits, and research on changing ecosystems, including climate impacts, are all essential components of functioning fisheries management.
We urge the Administration to ensure that U.S. fisheries management continues to rely on the Best Scientific Information Available—a principle that has long served fishers, managers, and the nation well. But federal budget cuts, layoffs, and other attempts to reduce the workforce obstruct public services and erode the knowledge, skills, and experience needed to sustainably manage our nation’s fisheries. We have been down this path before. New England fisheries were some of the most diversified and productive, sustaining the settlement of this nation and supporting coastal communities for generations. But underregulated fishing and a poor understanding of stock abundances led to the widespread depletion of resources and the demise of many businesses. In response, Congress developed regulations and programs, including scientific efforts, to help the failing fishing communities. Since the Magnuson–Stevens Act of 1976, bipartisan efforts among scientists, industry, and policymakers have built effective regulatory frameworks and scientific capacity that work. As of June in this year, 22 of 25 stocks in the heavily overfished Northeast region were recovered to fishable levels.3 The keys to these successes have included:
Data collection: Management is data driven. Federal fisheries-independent surveys deployed throughout the year across territorial waters, biological sampling of the catch (via observer coverage, port sampling, and the Marine Recreational Information Program [MRIP]), and environmental monitoring provide the data necessary to assess population trends and establish sustainable fishing quotas. A lack of funding to maintain NOAA vessels, sampling gear, and staff has caused survey cancellations and a loss of coverage in recent years. This is notable in many areas across the nation, but in Alaska where the unprecedented closure of the snow crab fishery in 2022 caused enormous losses for industry, a loss of survey coverage makes management even more tenuous. Missing data means that old data must be used to inform new catch limits. This does not serve the best interests of industry and instead works against them. To maximize quotas, current and comprehensive data collection must occur.
Stock assessment: Population models built by stock assessors provide the science on which independent Fisheries Councils rely to make management decisions for their stakeholders. Federal worker capacity and funding for stock assessment have been stretched too thin for decades, meaning core functions at NMFS cannot occur or have been severely hampered. Deadlines to open fisheries have been missed, opportunities for industry input have been cancelled, and models have not been updated with new knowledge because the Divisions involved in stock assessment and monitoring are staff and funding deficient. This problem has been exacerbated in 2025 with early retirements, the hiring freeze, and budget reductions, which also freezes a merit-based employment pathway for new recruits under a program launched in 1999 to alleviate the skilled worker shortage (NMFS-Sea Grant Population and Ecosystem Dynamics Fellowship). To meet the needs of industry, stock assessment hiring must be reopened along with appropriate funding levels.
We urge the Administration to prioritize the revitalization of the monitoring and assessment functions of the National Marine Fisheries Service by exempting them from future reductions in force and allowing hiring to repopulate the core functions of fisheries management so that accurate, timely fisheries catch quotas can be achieved.
Flexibility and Cooperative Research
Flexibility is needed now more than ever as renewed interest in domestic fisheries coincides with supply chain disruptions, shifts in consumer demand for domestic seafood,1 and rapidly changing ecosystems that increase uncertainty in yield projections. Flexibility, however, is not at odds with science-based management. With adequate funding, innovation and collaboration with industry can advance new data collection methods, analyses, and management approaches. In the Western Pacific, the greatest challenge is the lack of reliable data across 1.5 million square miles of ocean; similarly, the Southeast region covers three large marine ecosystems: the Gulf of America, South Atlantic, and Caribbean. Unlike northern U.S. regions where annual stock assessments and data collection were feasible until recent disruptions, these vast areas depend heavily on uncertain projections spanning numerous years. Many species appear underutilized because limited and variable participation mask true stock status—sometimes allowing a single operator to take an entire quota. Innovation and flexibility are essential here to improve the Best Scientific Information Available. Expanding cooperative research to increase data streams and provide financial support to collaborating industry partners and developing improved methods to integrate industry and recreational data can strengthen science-based management and support sustainable fisheries across the regions and the nation.
In cases where regulatory updates are needed, limited funding and staffing hamper progress to remove these hurdles. In 2018, a working group of scientists and industry hosted by NOAA was formed to evaluate a potential cause for the lack of recovery of cod in the Northeast. Their recommendations were forwarded to the Research Track Working Group, that included NOAA scientists and volunteers, for evaluation. The group concluded in 2023 that regulatory changes were warranted. However, the working group recommendations were still under review by NMFS at the start of fishing in May 2025. This was a regulatory bottleneck that resulted in emergency action to prevent a fishery shutdown. To stay in line with the needs of the fishing industry, more resources are needed at NMFS to be able to not only keep up with current assessment schedules but also to be able to evaluate more rapidly where regulations can change and act upon them.
Changing Environmental Conditions
Changes in the ocean environment, including warming, storms, and acidification, are altering ecosystems, changing stock productivity, and causing widespread shifts in the distribution of many exploited species. Numerous studies show that it is imperative to preserve a minimum stock size and age structure, protect reproductive females and spawning congregations, and maintain a portfolio of fisheries resources to buffer against fishery losses. We must continue to research changing ocean conditions, shifting species distributions, and population dynamics to inform the fishing portfolio, the associated regulatory needs such as flexible permitting, and resource managers’ risk assessments that can alter catch advice (based in part on the assessment of environmental disruption). A major buffer to environmental change is continued support for healthy habitats and ecosystems.
Habitat
Healthy and sustainable fisheries require healthy habitats and associated ecosystems. Yet, some of our most productive estuaries and coasts are compromised by threats such as contamination, habitat loss and alteration including loss of aquatic connectivity, and invasive species.4 Efforts to increase fisheries yields without also simultaneously restoring and protecting habitat have a high likelihood of failing. In contrast, areas with higher levels of protections such as national marine sanctuaries and monuments have been shown to increase yield for fishing industries, such as increased tuna catch rates after the expansion of the Papahānaumokuākea Marine National Monument.5 We urge the Administration to consider the cascading impacts to the fisheries economy that can result poor habitat. Failure to conserve habitat puts fish stocks at risk, threatens the livelihoods of the next generation of fishermen, and puts our coastal economies at great risk.
The bipartisan Infrastructure Investment and Jobs Act (IIJA, aka BIL) was a hallmark investment in infrastructure that supported restoring habitat and fish passage for the benefit of fisheries. This investment is helping improve the health of ecosystems and collaboration between federal, state, and Tribal partners. We support federal capacity within the programs established under IIJA such as NMFS’ Aquatic Ecosystem Connectivity work to increase the potential for return on this major investment.
Expansion of Sustainable Open Ocean Aquaculture
Responsibly managed aquaculture, including open ocean aquaculture in U.S. federal waters, is a critical tool for increasing sustainable protein, reducing pressure on wild capture fisheries, and providing waterfront investment in coastal communities that will benefit the seafood sector. The demand for food is expected to grow significantly in the next decade, but it is unlikely that wild capture fisheries can sustainably accommodate increased harvest pressure to help meet this demand. Expanding domestic seafood supplies through aquaculture in the open ocean can address America’s ongoing dependence on imported seafood, improve food security, relieve pressure on wild stocks, and boost investments in waterfront communities.
Significant advances in fish farming technology and the use of best management practices in farming operations have decreased the environmental footprint of aquaculture. AFS supports a clear, predictable, regulatory framework that will enable the growth of sustainable aquaculture, including open ocean aquaculture, in the U.S. Continued, consistent investments in research will further support sustainability.
We support the work of NMFS’ Aquaculture Program to coordinate across agencies towards a comprehensive regulatory foundation for open ocean aquaculture. We support the important siting analysis for future Aquaculture Opportunity Areas (AOAs) in federal waters, interagency coordination on National Environmental Protection Act (NEPA) review and Environmental Impact Statements (EIS), development of science-based tools and modeling, and associated economic development programs to support expansion of aquaculture into the Exclusive Economic Zone. In addition, we fully support the work of the National Centers for Coastal and Ocean Science for its role in the development of the AOAs and the coastal planning tools it offers to assist managers, planners, and industry with sustainable aquaculture development. We urge you to provide funding to maintain this program and support this important work.
The American Fisheries Society stands ready to provide scientific expertise on these and other challenges facing our nation’s fisheries and advice on conservation solutions. Thank you for your consideration.
Sincerely,
Jeff Kopaska
Executive Director
References
1. FAO. 2024. The State of World Fisheries and Aquaculture 2024 – Blue Transformation in Action. Rome. https://doi.org/10.4060/cd0683en
2. Costello C, Ovando D, Clavelle T, Strauss CK, Hilborn R, Melnychuk MC, Branch TA, Gaines SD, Szuwalski CS, Cabral RB, Rader DN, and Leland A. 2016. Global fishery prospects under contrasting management regimes. Proceedings of the National Academy of Sciences 113: 5125–5129. https://doi.org/10.1073/pnas.1520420113
3. NMFS. 2025. National Marine Fisheries Service – 2nd Quarter 2025 Update. Silver Spring. www.fisheries.noaa.gov/s3/2025-07/Q2-2025-Stock-Status-Tables.pdf
4. Kennish MJ. 2002. Environmental Threats and Environmental Future of Estuaries. Environmental Conservation 29(1): 78–107. doi:10.1017/S0376892902000061
5. Medoff S, Lynham J, and Raynor J. 2022. Spillover Benefits from the World’s Largest Fully Protected MPA. Science 378(6617): 313–16. https://doi.org/10.1126/science.abn0098
